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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`___________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`___________________
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`BROADSIGN INTERNATIONAL, LLC
`Petitioners
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`v.
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`T-REX PROPERTY AB,
`Patent Owner
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`U.S. Patent No. RE39,470
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`___________________
`
`Inter Partes Review Case No. 2016-01869
`___________________
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`
`DECLARATION OF ZAYDOON JAWADI
`IN SUPPORT OF PATENT OWNER’S PRELIMINARY RESPONSE
`PURSUANT TO 37 C.F.R. § 42.107(a)
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`Patent No. RE39,470
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`TABLE OF CONTENTS
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`
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`I.
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`INTRODUCTION .......................................................................................... 1
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`II.
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`SUMMARY OF CONCLUSIONS ................................................................ 1
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`III. BACKGROUND AND QUALIFICATIONS ................................................ 1
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`IV. MATERIALS REVIEWED ........................................................................... 4
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`V.
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`FIELD OF THE INVENTION ....................................................................... 4
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`A. Digital Signage ...................................................................................... 4
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`B.
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`C.
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`Person of Skill in the Art at the Time of the Invention ......................... 6
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`Background of the Technology ............................................................. 7
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`VI. CLAIM CONSTRUCTION ........................................................................... 8
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`A.
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`“dynamically updating,” “permitting said exposure list to be
`dynamically updated,” and “means for . . . dynamically updating
`an exposure list” .................................................................................... 8
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`VII. GROUND 1 – ALLEGED OBVIOUS OVER NAKAMURA AND
`LOBAN ......................................................................................................... 13
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`A. Nakamura and Loban do not disclose “dynamically updating an
`exposure list,” “permitting said exposure list to be dynamically
`updated,” or “means for . . . dynamically updating an exposure
`list.” .....................................................................................................13
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`B.
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`Nakamura and Loban do not disclose “interrupting said display of
`material by said select projectors when said display is hidden,
`obstructed, or otherwise visibly unavailable in said public place.” ....19
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`VIII. GROUND 2 - ALLEGED OBVIOUSNESS OVER NAKAMURA,
`LOBAN, AND REILLY ............................................................................... 20
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`A.
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`The Nakamura-Loban-Reilly combination in Petitioners’ theory
`for claims 7, 9, 19, and 21 does not practice “dynamically
`updating an exposure list” ...................................................................20
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`IX. GROUND 3 - ALLEGED ANTICIPATION OF NAKAMURA ................ 21
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`X.
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`CONCLUSION ............................................................................................. 22
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`iii
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`I, Zaydoon Jawadi, hereby declare as follows:
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`I.
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`INTRODUCTION
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`1.
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`I have been retained by T-Rex Property AB, in this action. My
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`credentials are described in my CV, which is Exhibit 2002. I offer this report on
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`the technology at issue in U.S. Patent No. RE39,470 in response to the Petition for
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`Inter Partes Review, Case No. 2016-01869, filed by Petitioner BroadSign
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`International, LLC.
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`2.
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`I have been asked by T-Rex’s counsel to offer technical opinions
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`relating to U.S. Patent No. RE39,470 and the alleged prior art and arguments
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`presented by the Petitioners and their expert. I am being compensated for my work.
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`My compensation is not related to the outcome of this case.
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`II.
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`SUMMARY OF CONCLUSIONS
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`3.
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`As a result of performing the analysis described herein, and applying
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`the standards outlined below in Section IV, I have determined that, in my opinion,
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`none of Petitioners’ proposed Grounds 1-3 provide a basis for concluding that any
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`of the claims of the ’470 Patent should be found invalid. My opinion is supported
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`by the evidence in the patent specification, figures and claims, as well as the
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`disclosures of the alleged prior art and the other documents cited below.
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`III. BACKGROUND AND QUALIFICATIONS
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`4.
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`As shown in my CV (Exhibit 2002), I have a Bachelor of Science in
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`Electrical Engineering from Mosul University, a Master of Science in Computer
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`Science from Columbia University, and over 35 years of experience in software
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`development, engineering, consulting, and management in the fields of computing
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`systems, Internet, web technologies, data storage, data networking, software
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`applications, telephony, and telecommunication.
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`5.
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`In 2010, I cofounded and am the President of Rate Speeches, Inc., an
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`Internet company providing online communication rating and evaluation services.
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`6.
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`From 2001 to 2006, I was President and cofounder of CoAssure, Inc.,
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`a provider of automated web-based telecommunication test services.
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`7.
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`From 1999 to 2001, I was CEO, Chairman, and founder of Can Do,
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`Inc. an Internet eCommerce and community company.
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`8.
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`From 1992 to 1996, I was President and founder of Zadian
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`Technologies, Inc., a supplier of data storage test systems, with over 50,000 units
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`installed worldwide.
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`9.
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`In 1996, Zadian Technologies was acquired by Xyratex International
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`LTD (NASDAQ: XRTX, which was acquired by Seagate, NASDAQ: STX, in
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`2014). Following Zadian's acquisition by Xyratex, I became a general manager at
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`Xyratex until 1998. At Xyratex, I was responsible for a data networking analysis
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`tools business unit, which designed and built Gigabit Ethernet network protocol
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`analysis and monitoring products, which were sold, under OEM agreement, by the
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`largest network protocol analysis and monitoring products supplier.
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`10. Prior to 1992, I worked as a software consultant, a software engineer,
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`and an electrical engineer.
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`11. My experience specifically relevant to the digital signage includes
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`being general manager of a data networking analysis tools business unit at Xyratex,
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`1997-1998, being general manager of a manufacturing test systems division at
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`Xyratex, 1996-1996, and being president of a manufacturing test systems supplier,
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`Zadian Technologies, 1992-1996. The Xyratex and Zadian manufacturing test
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`systems comprised multiple individual test units (each with an independent LCD
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`display operated by an embedded system) connected through a network to a central
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`control system; the central control system has the ability to control the displays of
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`the individual test units. My experience (1984-1992) also includes designing and
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`implementing networked individual devices (each with an independent display
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`operated by embedded system or PC) connected through a network to central
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`control systems that control the display of the individual devices, and includes
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`designing and implementing database, applications, and system software as well as
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`drivers and other software for controlling graphics and monitor displays. In
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`addition to my technical work, my background includes being involved with direct
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`marketing and advertising at Zadian Technologies (1992-1996), at Xyratex (1996-
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`1998), at Can Do (1999-2001), at CoAssure (2001-2006), and at Rate Speeches
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`(2010-present).
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`IV. MATERIALS REVIEWED
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`12.
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`In performing my analysis, I have reviewed, among other things, the
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`T-Rex Patent and T-Rex’s Preliminary Response in these proceedings. I have also
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`reviewed the Petition and the declaration of Dr. Jaime G. Carbonell in support of
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`the Petition. Additionally, I have reviewed all of the prior art cited by Petitioners
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`in their Petition. I have reviewed the portions of the prosecution history and
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`reexamination history of the ’470 Patent cited by Petitioners and their expert. I
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`have also reviewed various other documents which are discussed later herein.
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`13. For the purposes of this declaration, I have assumed the correctness of
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`the legal standards applied by Dr. Carbonell in paragraphs 13 to 22 of his report,
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`and for the purposes of this declaration, have applied the same legal standards. I
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`reserve the right to describe and rely on other legal standards in connection with
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`any future declaration I submit in this or any other proceeding.
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`14. For consistency and ease of review, all of my column and line
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`citations to the patent specification are in “(column:line)” format.
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`V.
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`FIELD OF THE INVENTION
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`A. Digital Signage
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`15. Traditional out-of-home advertising (AKA outdoor advertising), such
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`as billboards, bulletins, notice boards, posters, banners, and brochures, is being
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`replaced with electronic signage, and, more recently, digital signage. Digital
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`signage utilizes various digital display technologies, such as LCD, LED, computer
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`monitors, flat screen monitors, projectors, digital television sets, overhead screens,
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`wall-mounted screens, and other display devices. Digital signage may be used to
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`display images, video, text, and other content to convey information, such as
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`transportation schedules and timetables, passenger information, updates, news,
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`weather, traffic, corporate and informational messages, warnings, etc. or for
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`advertising. Digital signage may be deployed in airports, train stations, railway
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`station platforms, subway stations, subway platforms, ship harbors, bus stations,
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`hospitals, sports arenas, theaters, movie theaters, concert halls, hotels, stadiums,
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`museums, conferences, exhibitions, assembly halls, lecture halls, conference rooms,
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`shopping malls, retail stores, restaurants, corporate buildings, etc. Digital signage
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`allows both digital information and digital advertising to be displayed in public
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`infrastructures and places that are accessible to and frequented by a general public.
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`Digital signage technology involves digital display devices, possibly with local
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`computers or processing devices, connected through communications medium,
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`such as dedicated cables, local area network (LAN), wide area network (WAN), or
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`wireless. The devices may be managed remotely. Digital signage technology
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`involves hardware and software.
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`B.
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`16.
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`Person of Skill in the Art at the Time of the Invention
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`In paragraph 11 of the Carbonell Declaration, Dr. Carbonell opines
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`that a person of ordinary skill in the art in the field of the ’470 Patent at the time of
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`its invention (a “POSITA”) “would possess at least a bachelor of science degree in
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`electrical engineering or computer science (or equivalent degree or experience)
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`with practical experience or coursework in the design or development of systems
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`for display control in a networked environment.” Ex. 1006 ¶ 11.
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`17. For the purposes of this declaration, I have assumed the correctness of
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`the scope of a POSITA in the field of the ’470 Patent at the time of its invention
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`applied by Dr. Carbonell in paragraph 11 of his report. I reserve the right to
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`describe and rely on a different scope of a person of ordinary skill in the art in the
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`field of the ’470 Patent at the time of its invention in connection with any future
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`declaration I submit in this or any other proceeding.
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`18.
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`I understand that my qualifications and experience exceed those of a
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`POSITA as defined by Dr. Carbonell in paragraph 11 of his report. Nevertheless,
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`my analysis and opinions in this declaration about the ’470 Patent are based on the
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`perspectives of a POSITA as of April 1996 as defined by Dr. Carbonell in
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`paragraph 11 of his report.
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`C. Background of the Technology
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`19. The specification of the ’470 Patent describes a number of related but
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`distinct technologies; however, the ’470 Patent is primarily directed to a digital
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`information system that dynamically controls and coordinates remote digital
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`signage displays using information provided by external information mediators.
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`Ex. 1001 cls. 1-26. In particular, a primary concern of the ’470 Patent is the
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`problem of how to provide a flexible system in which external information
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`mediators are able to dynamically control the transmission of display instructions
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`to a larger public in different places situated at any chosen distance apart through
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`displays. Ex. 1001 at 2:40-45. For instance, the patent describes that, at the time
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`of the invention, “information media is not coordinated, but is in the form of
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`individual items which are controlled and updated separately, often manually.” Ex.
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`1001 at 1:34-36. The patent further explains that “[a]lthough the administration of
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`information is often processed manually with the aid of modern computer
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`technology, the available display time will nevertheless contain “dead time”,
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`among other things due to back-logging caused by the manual infeed process.” Ex.
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`1001 at 1:48-53. The patent further explains that “present-day systems do not
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`enable information to be updated dynamically for display in real time. Neither do
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`present-day systems enable external mediators to update information for display in
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`a central control system, nor yet the administrator who makes the display of
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`information available, but it is the administrator who determines when, where and
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`how the information shall be displayed.” Ex. 1001 at 54-57.
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`20. Another primary concern of the ’470 Patent is “to enable a picture,
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`image or other information to be changed in practice as often as is desired, in real
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`time, therewith providing direct and immediate communication.” Ex. 1001 at
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`2:49-53. The patent also explains that “it should be possible to update and change
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`the information quickly.” Ex. 1001 at 2:26-27. The patent further explains that
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`“the digital information system is able to insert a change at short notice or to
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`operate a completely new spot.” Ex. 1001 at 9:23-25. The patent explains that this
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`means that “[t]he system is thus highly flexible and enables quick changes to be
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`made with regard to what shall be exposed on the exposure means, where it shall
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`be exposed and when.” Ex. 1001 at 9:25-28.
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`VI. CLAIM CONSTRUCTION
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`A.
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`“dynamically updating,” “permitting said exposure list to be
`dynamically updated,” and “means for . . . dynamically updating
`an exposure list”
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`21. The terms “dynamically updating,” “permitting said exposure list to
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`be dynamically updated,” and “means for . . . dynamically updating an exposure
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`list” are recited in claims 1, 13, 25, and 26 of the ’470 Patent, and is thus a
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`limitation directly or through dependency of all of the claims at issue in this
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`proceeding. I understand that Petitioners and their expert have not taken a position
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`regarding the construction of “dynamically updating” or “permitting said exposure
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`list to be dynamically updated.” I further understand that Petitioners and their
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`expert have taken the position that “means for generating and dynamically
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`updating an exposure list” should be construed as an “exposure handler.”
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`22.
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`I understand that T-Rex has proposed that the term “dynamically
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`updating” be construed as “updating the exposure list in response to user actions
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`when and as needed,” the phrase “permitting said exposure list to be dynamically
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`updating” be construed as “allowing the exposure list to be updated in response to
`
`user actions when and as needed,” and the phrase “means for . . . dynamically
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`updating an exposure list” be construed as “an exposure handler allowing the
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`exposure list to be updated in response to user actions when and as needed.” It is
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`my opinion that T-Rex’s construction is the broadest reasonable interpretation of
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`these terms from the claims of the ’470 Patent, from the perspective of one of
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`ordinary skill in the art informed by the specification. In particular, the evidence
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`establishes that T-Rex’s construction is the ordinary meaning of the term at the
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`time of the invention.
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`23.
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`In the fields of engineering and computer science, the concept of
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`dynamically updating is well-known. An example of dynamically updating is
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`described in the fourth edition of the Microsoft Computer Dictionary in the
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`definition of “dynamic HTML.” In particular, the fourth edition of the Microsoft
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`Computer Dictionary defines “dynamic HTML” as “A technology designed to add
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`richness, interactivity, and graphical interest to Web pages by providing those
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`pages with the ability to change and update themselves dynamically, that is, in
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`response to user actions, without the need for repeated downloads from a server.”
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`Ex. 2003 at 158 (emphasis added). Dynamic HTML is a well-known umbrella
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`term for a collection of technologies that use scripting languages to change
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`variables used in a web page to affect the look and function of an HTML page
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`while a user views the page.
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`24. Further support is found in the fourth edition of the Microsoft
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`Computer Dictionary’s definition of “dynamic”: “describ[ing] some action or
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`event that occurs when and as needed.” Ex. 2003 at 158 (emphasis added).
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`25.
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`In my opinion, T-Rex’s construction is also consistent with the plain
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`and ordinary meaning of the term as a person of ordinary skill in the art at the time
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`of the invention would understand it after reviewing the specification. In particular,
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`the specification teaches that “it should be possible to update and change the
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`information quickly.” Ex. 1001 at 2:26-27. The specification describes the
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`ramifications of not dynamic updating, stating that “the displays on which
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`information is presented will often become static, for instance show the time of the
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`next display or show a pause picture, i.g. [sic] dead time. This becomes nerve-
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`wracking to travellers [sic], who often wait for long periods in waiting halls or
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`stand on platforms.” Ex. 1001 at 2:29-33. The specification further explains that
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`one object of the invention is “to enable a picture, image or other information to be
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`changed in practice as often as is desired, in real time, therewith providing direct
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`and immediate communication.” Ex. 1001 at 2:49-53. The specification further
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`explains that “an external information mediator 24 is able to put through
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`information to the system 12 twenty-four hours a day, whereupon the information
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`can be included instantaneously in the exposure list.” Ex. 1001 at 5:30-35. The
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`specification also explains that “the digital information system is able to insert a
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`change at short notice or to operate a completely different spot. The system is thus
`
`highly flexible and enables quick changes to be made with regard to what shall be
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`exposed on the exposure means, where it shall be exposed and when.” Ex. 1001 at
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`9:23-28. It is my opinion that a POSITA at the time of the invention would
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`understand these disclosures to mean that the invention includes the ability to
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`update the list of exposures as needed based on input from the user or external
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`information mediator.
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`26. The specification also provides an alternative to the dynamic updating
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`of the exposure list where “[p]ersonnel at the working stations 32 are thus able to
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`interrupt any queue lists in the server 1 to update the exposure list,” in contrast to
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`updating the exposure list in response to user actions. Ex. 1001 at 8:10-34.
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`27. The specification also distinguishes “updating” from “generating” and
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`“organizing.” For example, claim 1 recites “generating, organizing, and
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`dynamically updating an exposure list.” Ex. 1001 cl. 1. It is my opinion that a
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`person of skill in the art at the time of the invention would have understood claim 1
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`to recite “generating,” “organizing,” and “dynamically updating” as distinct, but
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`related, concepts.
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`28. To the extent Petitioners’ proposed construction for “means for
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`generating and dynamically updating an exposure list” is inconsistent with T-Rex’s
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`construction for “means for . . . dynamically updating an exposure list,” I disagree
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`with the construction proposed by Petitioners. It is my opinion that such a
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`construction is inconsistent with the broadest reasonable construction of the
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`“dynamically updating” terms in the claims of the ’470 Patent from the perspective
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`of one of ordinary skill in the art, informed by the specifications and teachings of
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`the patent. In particular, such a construction ignores the separate use of the terms
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`“generating,” “organizing,” and “dynamically updating” in claim 1. Ex. 1001 cl. 1;
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`see also ¶ 27 supra. Additionally, such a construction ignores the plain and
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`ordinary meaning of “dynamically updating,” as I discuss above in paragraphs 21
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`through 26. See ¶¶ 21-26 supra; see also Ex. 2003 at 158-59 (MS Dictionary
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`cites); see also Ex. 1001 at 2:26-27, 49-53, 5:30-35, 8:10-34, 9:23-29.
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`VII. GROUND 1 – ALLEGED OBVIOUS OVER NAKAMURA AND
`LOBAN
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`A. Nakamura and Loban do not disclose “dynamically updating an
`exposure list,” “permitting said exposure list to be dynamically
`updated,” or “means for . . . dynamically updating an exposure
`list.”
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`29.
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`In regards to proposed Ground 1, Petitioners’ theory for claims 1-3, 5-
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`9, 12-14, 17-21, and 25 includes the supposition that the combination of Nakamura
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`and Loban would practice the limitations “dynamically updating an exposure list,”
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`“permitting said exposure list to by dynamically updated” and “means for . . .
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`dynamically updating an exposure list.”1 I disagree with Petitioners’ theory for
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`proposed Ground 1 for the following reasons.
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`30. As described above, it is my opinion that the appropriate construction
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`of the term “dynamically updating” is “updating the exposure list in response to
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`user actions when and as needed,” the appropriate construction of the phrase
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`“permitting said exposure list to be dynamically updating” is “allowing the
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`exposure list to be updated in response to user actions when and as needed,” and
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`the appropriate construction of the phrase “means for . . . dynamically updating an
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`exposure list” is “an exposure handler allowing the exposure list to be updated in
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`response to user actions when and as needed.”
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`1 For clarity, I will hereinafter refer to these three limitations collectively as “the
`dynamically updating limitations.”
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`31.
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`It is my opinion that Nakamura does not disclose “dynamically
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`updating an exposure list,” “permitting said exposure list to be dynamically
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`updated,” or “means for . . . dynamically updating an exposure list.” To the
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`contrary, Nakamura does not teach updating the reservation information stored in
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`the master station when and as needed, nor does Nakamura teach updating
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`reservation information stored in the master station based on user action.
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`32. From my review, the Nakamura patent application does not teach
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`updating stored reservations; instead, the Nakamura patent application teaches only
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`receiving and storing new reservations. For instance, Nakamura explains that
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`“[w]hen the display reservations are received from an operator, the reservation
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`periods created from the first to several orders are sequentially filled, and
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`reservations are cut off when posting time is no longer available. If any time were
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`to remain available, the display time 6 for individual reservations are arranged so
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`that the posting reservation time frame T is filled with all the reservations that
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`came in before the final reservation cut-off time. . . .” Ex. 1007 at 0017.
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`Nakamura further states that “[t]he conditions for the posting reservations and the
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`costs are decided by sequentially limiting the location and time.” Ex. 1007,
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`Abstract. Nakamura also describes “dividing the display reservation cut off period
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`for the selected specific slave stations into several periods, sequentially distributing
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`and editing the display reservations to be displayed in the same posting reservation
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`time frame received during each of the 1st to the Nth reservation periods[.]” Ex.
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`1007 at 0009. In my opinion, a person of skill in the art at the time of the invention
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`would understand this disclosure to mean that the system of Nakamura accepts
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`reservations on a first-come, first-serve basis, cutting off additional reservations
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`once the posting time is no longer available. It is further my opinion that a person
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`of skill in the art at the time of the invention would not understand this disclosure
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`to include “dynamically updating.”
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`33. Another disclosure of Nakamura relied upon by Petitioners to satisfy
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`the disclosure of the “dynamically updating” limitations explains that “the present
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`invention is characterized by updating the display information of the display
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`content posting support software by dividing the display reservation cut off period
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`for the selected specific slave stations into several periods, sequentially distributing
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`and editing the display reservations to be displayed in the same posting
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`reservation time frame received during each of the 1st to the Nth reservation
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`periods, while distributing the idle time remaining in the posting reservation time
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`frame before and after each of the reserved display runtime during the reservation
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`period to adjust for overlapping display reservations, setting the display duration
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`for each of the display reservations by adding the idle time to the display
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`runtime at the end of the final reservation period, and successively registering
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`the display reservation status with the master station.” Ex. 1007 at 0010 (emphasis
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`added). It is my opinion that a person of skill in the art at the time of the invention
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`would understand this disclosure to explain that the system of Nakamura modifies
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`the reservation information supplied at the terminal devices to adjust for
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`overlapping reservations and idle time before registering the display reservation
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`status with the master station, and not based on user action. See Ex. 1007 at 0010.
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`It is my opinion that a person of skill in the art at the time of the invention would
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`not understand this disclosure to meet the “dynamically updating” limitations.
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`34. Another disclosure of Nakamura relied upon by Petitioners to satisfy
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`the disclosure of the “dynamically updating” limitations explains that “[t]he
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`reserved display contents are stored by the system 10, including the master station
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`2, and the system 10 executes the display after allocating the posting time and
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`performing a prescribed editing so as not to compromise public order and
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`standards of decency.” Ex. 1007 at 0018 (emphasis added). It is my opinion that a
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`person of skill in the art at the time of the invention would understand this
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`disclosure to explain that the system can be set up by the administrator to perform
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`certain edits, such as conforming to decency standards, when allocating the posting
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`time, and that such edits are not the result of user action. See Ex. 1007 at 0018. It
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`is my opinion that a person of skill in the art at the time of the invention would not
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`understand this disclosure to meet the “dynamically updating” limitations.
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`35. Another disclosure of Nakamura relied upon by Petitioners to satisfy
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`the disclosure of the “dynamically updating” limitations explains that “the decision
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`would be made to edit the reservations a to d to rearrange the firm reservation
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`order as shown at the bottom of the figure, and the display order executed.” Ex.
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`1007 at 0025 (emphasis added). It is my opinion that a person of skill in the art at
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`the time of the invention would understand this disclosure to explain that the
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`system can be set up to rearrange the display order. See Ex. 1007 at 0025. It is my
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`opinion that a person of skill in the art at the time of the invention would not
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`understand this disclosure to meet the “dynamically updating” limitations,
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`especially because the patent distinguishes between “organizing” and “dynamically
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`updating” the exposure list. See 1001 at cl. 1 (claiming “generating, organizing,
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`and dynamically updating the exposure list”). The disclosure continues, “At this
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`point, the display runtime t is set by distributing the idle time t2 remaining in the
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`posting reservation frame T so that it is most beneficial for the order of the
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`reservations, for example in the order of a, b, and c, which were committed in the
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`earlier reservation periods.” Ex. 1007 at 0025. It is my opinion that a person of
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`skill in the art at the time of the invention would understand this disclosure to
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`explain that the system can be set up to add idle time evenly across reservations
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`when allocating the posting time, and that such edits are not the result of user
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`action. See Ex. 1007 at 0025. It is my opinion that a person of skill in the art at
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`the time of the invention would not understand this disclosure to meet the
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`“dynamically updating” limitations.
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`36.
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`It is my opinion that Nakamura does not disclose dynamically
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`updating an exposure list. Even if the Board concludes that Nakamura discloses
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`updating an exposure list, the disclosures that Petitioners rely on from Nakamura at
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`best only teach modifying the received reservations based on the system’s own
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`pre-configured internal requirements rather than based on user actions.
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`37. Accordingly, it is my opinion that none of the disclosures of
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`Nakamura relied upon by Petitioners for the “dynamically updating” limitations
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`would be understood by a person of skill in the art at the time of the invention as
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`disclosing the “dynamically updating” limitations.
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`38. From my review of the petition and the Carbonell declaration,
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`Petitioners do not identify any disclosure of Loban as teaching the “dynamically
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`updating” limitations.
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`39.
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`It is my opinion that Loban, which teaches a video billboard for
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`outdoor use comprising one or more projectors, teaches neither the use of an
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`exposure list nor dynamically updating an exposure list.
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`40. Accordingly, it is my opinion that, because neither Nakamura nor
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`Loban teach the limitations “dynamically updating an exposure list,” “permitting
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`said exposure list to be dynamically updated,” or “means for . . . dynamically
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`updating an exposure list,” the combination of Nakamura in view of Loban would
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`not render obvious claims 1-3, 5-9, 12-14, 17-21, or 24-26.
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`B. Nakamura and Loban do not disclose “interrupting said display
`of material by said select projectors when said display is hidden,
`obstructed, or otherwise visibly unavailable in said public place.”
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`41.
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`In regards to proposed Ground 1, Petitioners’ theory for claim 3
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`includes the supposition that the combination of Nakamura and Loban would
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`practice the limitation “wherein said coordinating and controlling includes
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`interrupting said display of material by said select projectors when said display is
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`hidden, obstructed, or otherwise visibly unavailable in said public place.” Pet. at
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`38. I disagree with Petitioners’ theory for claim 3.
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`42.
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`In particular, Petitioners rely on the disclosure in paragraph 0018 of
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`Nakamura for the disclosure of “discontinuing the display of a certain amount of
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`content (e.g. high quality) when a vehicle is in transit.” Pet. at 38; Ex. 1006 ¶81. I
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`disagree with Petitioners and Petitioners’ expert. The relevant portion of
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`paragraph 0018 of Nakamura states: “With respect to transmission of display
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`data to specified slave stations installed in transportation equipment, such as
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`airplanes and busses, the quality of information can be higher if received when the
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`transportation equipment are parked at terminals rather than in transit.” Ex. 1007
`
`at 0018 (emphasis added). It is my opinion that a pers